Not Quite a Blog

In 2007, California Secretary of State Debra Bowen commissioned a review of California's voting systems by a team of technical experts, of which I was one.

She released many of the technical reports on the night of 27 July 2007 and then spent a week studying the results before issuing her decisions at a late night press conference on Friday 3 August 2007.

I recently had occasion to try and find the record of that statement, but it didn't seem anywhere to be found. Then, I remembered that I had captured the audio of the announcement:

http://josephhall.org/casos/ttbr-announcement/ttbr-announcement.mp3

It's a visceral, thoughtful piece of voting systems history that particularly highlights how careful, conservative and scientific Debra Bowen thinks and adjudicates. Below, I include the full transcript from the event... (I've posted those in HTML and TXT, as transcribed by the wonderful CastingWords.com).

CA SoS Bowen TTBR Decision Announcement

3 August 2007

Debra Bowen: I don't want to wait any longer. It's been a long evening as it is. So, good afternoon or evening or whatever it is. It reminds me a little bit of our old budget negotiation days. Apologies for the delay. Believe me, it was not by design.

Before I announce the actions that I have taken this evening, I want to talk briefly about the decisions and something about the rationale behind them.

The systems that we use to cast and tally votes in this state are the most fundamental tools of our democracy. And if, in this great nation, we do not have confidence, our citizens do not have confidence that elections have been correctly decided because they do not have faith in the integrity of the tools used in the conduct of elections, then elections officials have a duty to investigate the source of citizens concerns and a duty to take remedial action.

A democracy cannot long remain a democracy if a substantial number of its citizens have lost faith in the electoral process itself. I take my responsibilities as this state's chief elections officer very seriously. I am mindful of the impacts that my decisions will have on voters, on county and local elections officials, poll workers, voting system vendors, and on others in California and across the nation.

Every county's election results have consequences for the citizens of every other county. Every state's election results have consequences for the citizens of every other state. And every nation's election results have consequences for all of the people of the world. That's the nature of our independent world in the twenty-first millennium.

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Link: http://groups.ischool.berkeley.edu/podcast/audio/edley-pew-2008.mp3

The high-point of last weeks' Pew/JEHT conference, "Voting in America", was seeing the Dean of Berkeley Law, Chris Edley, give a keynote during dinner on Tuesday. With his permission, I am making available audio from his address. Find it here (30 minutes long and 18MB in size):

Chris starts by talking from the perspective of being part of the Obama transition team and to what extent election reform will be a focus. He then goes on to describe his views on federalism vs. localism in election administration, building a consensus vision for election reform and how we need to spark desire for election reform by arguing in terms of fundamental values.

Read on for my summary of his talk...

Disclaimer: any errors in the summary below are my own, and apologies for the few instances of side-talk in the audio.

In terms of the transition, he comes out the gate saying that there are, undoubtedly, more pressing matters demanding the incoming Presidents attention (i.e., the economy, national security, energy & climate change, health care, education and immigration):

I don't expect weekly meetings with the President to talk about election administration. Frankly, we probably don't want him to be having weekly meetings about election administration given [this list of priorities].

He then went on to the meat of his remarks, describing a few areas where he thinks reform should go forward.

He first talked about the divided philosophies at work in election administration. He was surprised in previous work, with the US Commission on Civil Rights and the Carter-Ford Commission, that many people involved with elections "think of the franchise as this precious jewel box that they have to guard carefully... and be very careful about who can hold it, open it and polish it." This is in contrast with people who consider voting as "something that should be shared widely so that democracy can flourish." Bridging this divide is one important assignment for election reformers... in his words: "The distinction between election administration and voting rights should disappear, and we should be united on an agenda of election rights."

Chris then went on to describe the complexity of the politics surrounding elections: "Our governance strategy for election administration [...] puts us in a situation where the infrastructure of our democracy is competing with potholes... and parks... and prisons... and health care... and pensions... and education." Federalism, often ends up protecting election officials when they make wacky, disparate decisions about the administration of elections. In Edley's view:

I would suggest to you that our aspirations for democracy in the 21st century are not the same as they were in the latter part of the 18th century. The strategy for bringing about the quality of democracy we want, I think is going to require some compromises on our commitments to localism in this arena. [...] I think we passed a milestone [in Florida 2000] in which localism is going to be increasingly forced to deal with the demands of a national sense of what is fair, what is efficient and what is truly democratic.

Edley then described how the real problems we have are in terms of inequality: the huge disparities in spoiled ballots, purged voters, waits in lines, etc.:

The question is whether the quality of the democratic infrastructure is coded to your ZIP code or your color. The next great challenge is to think of Bush v. Gore, not in the technical sense but in the aspirational sense, that everyone in the polity deserves the same quality of support for their effort to engage in the political process.

Edley does recognize that "fairness" is a large gray area, but that there are real problems in how "fair" our election experience actually is. Referencing the Governor of Virginia's comments that people wait in lines for other things---why not voting?---and the Secretary of State of Florida's similar comments that day about waiting in line at Disney World:

This is not Zimbabwe. We should not create a new poll tax in the form of a 2, 3, 4 hour wait to cast a vote.

That is, for example, large disparities in wait times within a jurisdiction are patently unfair. We need to work to address these sources of unfairness.

So, what are the next steps in Edley's mind? He made the point that national voter ID is not seen as an anathema in other countries. This is to say, by example, we need to use technologies to give us leverage to improve the process and promote fairness where we can:

[On the Carter-Ford Commission,] the reason were were enthusiastic about touchscreens is that we sensed the potential for assisting language minorities and people with disabilities. We sensed the potential of making voting as flexible as getting money out of an ATM; the possibility that the technology, wherever you were in the country, could flash on the screen the ballot appropriate for the jurisdiction in which we reside.

We should decide collectively what is that vision---5, 10, 15 years from now---so that we're moving in the same direction on multiple paths. That consensus-building effort is the single most important thing we can do in the next two years.

Edley then talked briefly about voter fraud. From his perspective, he sees largely unfounded claims about the extent of voter fraud. So he called for a substantial research investment in understand the characteristics of vote fraud.

He wraps his talk up about talking about fomenting reform via attention to nuts and bolts versus focusing change in terms of values:

What we have to do is not to improve the quality of election administration, what we have to do is be advocates for, be warriors for election rights. It's making people believe that they have a right to world-class infrastructure for this democracy. To let people believe they have a right to be able vote with ease and have their vote counted and have their officials be accountable. It's not just about public administration: it's about our freedoms, it's about our character and it's about our hopes. Now, that's sex.... and it's a hell of a lot more important than potholes.

Warning: This is a very long post.

Introduction

I've spent the past week looking over the voting equipment problems captured by the Election Protection Coalition's 25 nationwide call centers into the Our Vote Live database. There were around 1900 such incidents in the database, although that number is probably closer to 1700 taking into account duplicates.

Before I launch into the analysis, a few caveats:

• This is voter-reported data, which means it can be inaccurate.
• There has been no attempt to control for multiple reports from a single precinct.
• In many cases it is hard to tell what exactly happened as the incident reports were taken by mostly non-technical legal volunteers from mostly non-technical voters and volunteers in the field.
• Given the unbelievable popularity of the 1-866-OUR-VOTE hotline, OVL was unable to capture all incidents that people wanted to report.
• There are undoubtedly incidents that were not reported to the OVL hotline for a variety of reasons.

Bottom-line: This is useful for qualitative notions of what went wrong on election day.

While I've worked to make this post accessible to an audience that may not be familiar with the vagaries of voting technology, I just don't have enough time to explain everything. In that sense, I encourage you to ask questions (joehall@berkeley.edu) and I can amend this document to clarify as needed.

The Big Picture

Somewhere close to 85-90% of all voting equipment incident reports from the OVL database are very simple and report some combination of: broken equipment, long lines, and/or emergency ballots being handed out and/or auxiliary bins on optical scan systems being used (many optical scan systems have a bin incorporated into the design of the machine where ballots can be placed in the event the system ceases to function or the power remains out for hours). If we can do anything to improve the experience of the average voter facing a machine problem, it should be reduce the amount of time they spend in line.

Another curious feature of the data is the voters' uniformly negative attitudes toward contingency or back-up plans. Whenever the primary mode of voting is affected, whatever the contingency plan to keep people voting, it appears that voters are often upset and mistrustful. They seem to think that there is a possibility that their vote will not count if cast via a contingency plan. This is unfortunate as with any critical technical system, there should be a contingency plan in place that covers what to do if that system fails and how the system may continue or recover from that failure. For example, when an optical scanner goes down, the standard contingency plan is to place ballots in an auxiliary bin or container. Voters reported concerns with this kind of accommodation and were worried that their votes might not count. In a number of cases, voters refused to place their ballots into auxiliary bins and waited for hours before the scanner could be serviced or a new replacement scanner brought in. It's clear from this that we need to do a better job of educating voters as to what to do and what to expect in case of emergencies.

Ok, enough of the big picture; now on with the details!

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Yesterday, I filed my dissertation and got my sucker (Berkeley gives you a tasty See's Cafe Latte hard candy sucker when you graduate).

My dissertation is about a very poignant topic: policy mechanisms for making electronic voting systems more transparent. After refining what we mean when we talk about transparency, I examine open source, procurement contracts and auditing voting systems and show that each of these hold real promise for peeling back the layers of opacity in which we now find our voting systems enshrouded.

If you'd like to read it, here is a link and the abstract:

Policy Mechanisms for Increasing Transparency in Electronic Voting

In the early years of the American republic, only white male landowners could vote, and then typically by expressing their preferences in a public setting, for all to witness. Our electoral system has changed drastically since that time; now almost all Americans cast votes with the assistance of computerized equipment. While much good stems from the use of computerized equipment in elections—notably increased efficiency, enfranchisement and flexibility—unintended consequences of this mechanization have left us with complicated, insecure and opaque voting systems.

My PhD thesis focuses on the issue of transparency in evoting; that is, what public policy mechanisms can serve to make our voting systems less opaque? After exploring what we mean by “electoral transparency”, I examine the question of evoting transparency on three fronts. I analyze the role of disclosed and open source software in election systems and conclude that, while fully disclosed source code is a valid goal, limited disclosure to experts serves many of the same goals in the shortterm while preserving vendor trade secrecy. I investigate how contractual provisions between local election jurisdictions and voting system vendors serve to frustrate transparency and find that election officials need to be more careful in these negotiations. Finally, I turn to the question of auditing black box elections systems; that is, since we cannot know how these systems work in the fulldisclosure (“white box”) case, possibly because of contractual provisions that limit investigation, what methods and procedures can we use for “checking the math” behind our elections?

Aaron Burstein (UC Berkeley Law) and I just finished a large regulatory filing that will be of interest to any of you election technology geeks out there. Enjoy and be sure to let us know if you have feedback (there's another round of comments sometime in the future on a revised draft).

ACCURATE Submits Comments on the Voluntary Voting System Guidelines

5 May 2008

A Center for Correct, Usable, Reliable, Auditable and Transparent Elections (ACCURATE) submitted public comment today to the U.S. Election Assistance Commission on their draft Voluntary Voting System Guidelines (VVSG), urging the Commission to adopt certain key features fo the draft. The VVSG provides a national certification framework for U.S. voting systems against which 40 states require their voting systems to be certified.

ACCURATE's comments laud the new draft as a groundbreaking and badly needed overhaul of our national voting system standards while making constructive suggestions for further development.

The most significant element of the draft VVSG is the requirement for software independence, which would require voting systems to be designed so that undetected flaws in the voting system software cannot cause changes in the vote count. ACCURATE fully supports requiring software independence as the backbone of a robust and comprehensive next-generation voting system certification regime.

The commentary goes on to emphasize the importance of welcome features of the draft: adversarial vulnerability testing, volume testing, the new framework for usability and accessibility testing and comprehensive voting system documentation requirements. The comment closes by pointing out areas of the VVSG that will require increased institutional support outside of the VVSG process, including the crucial innovation class and a closed loop for incident reporting and feedback.

ACCURATE plans to participate further as the draft VVSG is modified and extended.

I’ll be giving my PhD thesis talk in 202 South Hall (UC Berkeley) on 5/14 (Wed) at 10am. Abstract below...

Public Policy Mechanisms for Increasing Transparency in Electronic Voting

Joseph Lorenzo Hall, UC Berkeley School of Information

Abstract:

In the early years of the American republic, only white male landowners could vote, and then typically by expressing their preferences in a public setting, for all to witness. Our electoral system has changed drastically since that time; now almost all Americans cast votes with the assistance of computerized equipment. While much good stems from the use of computerized equipment in elections---notably increased efficiency, enfranchisement and flexibility---unintended consequences of this mechanization have left us with complicated, insecure and opaque voting systems.

My PhD thesis focuses on the issue of transparency in e-voting; that is, what public policy mechanisms can serve to make our voting systems less opaque? After exploring what we mean by “governmental transparency”, I examine the question of e-voting transparency on three fronts. I analyze the role of disclosed and open source software in election systems and conclude that, while fully disclosed source code is a valid goal, limited disclosure to experts serves many of the same goals in the short-term while preserving vendor trade secrecy. I investigate how contractual provisions between local election jurisdictions and voting system vendors serve to frustrate transparency and find that election officials need to be more careful in these negotiations. Finally, I turn to the question of auditing black box elections systems; that is, since we cannot know how these systems work in the full-disclosure (“white box”) case, possibly because of contractual provisions that limit investigation, what methods and procedures can we use for “checking the math“ behind our elections?

On Tuesday I was a poll inspector at Alameda County precinct 225400. Since I am moving after I get my degree, this will likely be the last time I'll able to serve. This was the second time that I've served as the poll inspector this precinct in Oakland, CA. (The first was in November 2006.)

In the previous write-up, I explained a lot about the general working of our polling place. I won't repeat that kind of material here. I will describe the differences between the 2006 experience and this one and comment on parts of this election that stood out.

First, as I mentioned in a previous post, I was sick. In fact, I think I had the flu. This made running the polling place much, much more difficult as my mind wasn't entirely functional.

Another difference was that I brought my digital camera. I wanted to be able to take pictures of things I thought were interesting without, of course, taking images of any voters or ballots or any situations which might intimidate voters. I have a gallery up on Flickr of images I took that you are welcome to peruse:

Finally, this was, of course, the primary election after the California Top-to-Bottom Review. This meant increased security all around, a few specific new rules and a post-election audit, which will be conducted in the next few weeks. On the security side, there were a slew of new types of seals. Here are a few images of security seals:

	The DRE had a cable around it, sealed with a numbered pull-tight security seal.
	The Optical scanner had a cable around it too, secured with and adhesive seal like this and...
	with a pull-tight seal on the crimp point for the cable. In this image, you can also see the adhesive seal on the rear access panel.
	The adhesive seals seemed to be very good to me; here's what a removed seal looks like.
	The latches on the case of the DRE were protected as well with adhesive security seals. (good practice!)

Primary elections require a much more complicated process. I guess I hadn't realized how complicated primary elections can be. Keeping track of all the ballot styles was a challenge. Each party has it's own ballot in a primary (presidential or not) which quickly can multiply the number of ballot styles depending on if that party allows cross-over voting from "nonpartisan" or "decline-to-state" voters (interestingly, it's difficult to explain to a voter registered with the "American Independent" party that (s)he is, in fact, affiliated with a party instead of being "independent" of all political parties). This election had 6 partisan ballots, 3 non-partisan ballots, 3 languages for each ballot and a separate type of ballot stock for provisional ballots. That means 54 types of ballot styles that we might have to provide for a given voter.

My Team

My team was essentially the same team as in Nov. 2006. Our high school poll worker called in sick with the flu, so we had a replacement for her. Having 5 people man a polling place makes a big difference. When things are busy, 5 pollworkers means that all bases can be covered and that we can keep errors and delays to a minimum. Despite the heavy turnout, our line was only 10 people long at the busiest point in time.

Voting Technology Issues

We had one Sequoia AVC Edge II DRE voting machine and one Sequoia Optech Insight optical scanning machine. We set them up without difficulty before the polls opened at 7am. However, when I went to plug in the optical scanner, the unit did not power on. Despite moving the plug between outlets and checking the outlets with a lamp we had, it still would not power on. I called the Alameda RoV hotline and they said they'd have to call me back. Unfortunately, the building in which our precinct was located is impervious to cellphone signals, so that wasn't going to help. Fortunately, our poll coordinator, Carol, who oversaw a handful of nearby precincts, was able to contact the RoV again. The RoV authorized us to crack the security seal on the back of the scanner and make sure that the power cable was plugged in to the back of the scanner. Just as predicted, the cable had jiggled loose. Once we plugged it in, it was working great.

One of the consequences of the CA SoS's Top-To-Bottom Review was a new requirement that any DRE used for disability access must have a minimum of 5 votes cast on it if any one voter votes on it. This requirement was instated to ensure that a voter's votes remain private: if only one voter votes on a DRE, than the totals report will tell exactly how that voter voted. In November 2006, we had one blind voter and one voter with manual dexterity disabilities that had to use the DRE. These same voters returned to vote this year, which meant I was going to have to find a few other voters to vote on the DRE in order to meet the 5 voter requirement. I figured a bit of productive social engineering might work wonders here. So, as ballot officer--which means I distribute ballots to voters and activate the voter card for the DRE--I began to ask, "Would you like to vote on the machine or paper? Paper or plastic?" Most voters chose paper, but occasionally, a few voters would say, "Machine, of course."

That got me 4/5 of the needed DRE voters (one of the second disabled voters had not yet arrived and I couldn't be sure that he would arrive). I decided to surrender my own vote-by-mail ballot and vote on the DRE, a sacrifice of sorts, in order to get the last voter needed to meet the 5-voter requirement.

Voters with Disabilities

We had the same three voters with disabilities vote this year. In addition, we had two new voters that had challenges voting due to physical disabilities. We had one blind voter, one voter with manual dexterity disabilities and one voter in a wheelchair with full use of his hands. The two new voters were one voter in a Rascal (a three-wheeled mobility scooter) and a voter on crutches.

Each of these voters had few problems voting, save the blind voter, which I'll go into more detail in a second. Our precinct is accessible, technically, but the path to the door has a bunch of large flagstones with deep gaps between them, about 4 inches wide and about that deep. This made it difficult, but not impossible, for the Rascal and the wheelchair to enter the precinct.

The one "incident" of the day happened with the blind voter, who had few problems in November 2006. The blind voter signed our poll book with a signature stamp as usual. Our poll book listed his party affiliation as something that he disagreed with. He insisted that he had re-registered to be affiliated with a specific party. If this were a voter that could vote on paper, I would have issued a provisional ballot; more than likely, in that case, his votes for the partisan contest would not have counted unless his recollection of his registration status was correct. However, since this voter needed an audio ballot on the DRE, I wasn't sure if I could do a provisional audio ballot on the DRE for the party he claimed to be affiliated with. This sincerely incensed this voter. The voter questioned my competence, training and knowledge of voting technology. I told him that I was fully trained and that I knew more about these machines than perhaps any other poll inspector in our County. Plus, I said, it's our job to find a way for him to cast a vote, and we would make sure we found a way. Finally, I decided to authorize a voter card for an audio ballot for the party with which he claimed to be affiliated. I made a note that this should be considered a provisional ballot. Incidentally, while it took the DRE 30 minutes to load the audio files in 2006, it only seemed to take a few minutes this time.

Difficult Voters

We did have a few cases of difficult voters. An older woman, probably in her 80s, insisted that we had given her the wrong ballot. At first, this didn't seem so strange because many of the non-partisan voters who we gave non-partisan ballots to would return and say, "This ballot has no presidential race." Well, um, yeah... you're supposed to ask for the Democratic or American Independent ballot. Anyway, with this older voter, it quickly became clear that she had some other type of confusion. She had thought that she was supposed to get a ballot without any presidential race, despite that she was registered with a specific party. She argued with me for a bit until a helpful voter was able to pull out the book of sample ballots and she convinced herself she was mistaken. She then apologized profusely. One of the obvious challenges of being a poll worker is that there are very strict rules in certain cases and you can only be diplomatic up to a point, then the rules you've been taught have to be honored.

The same voter, when she was leaving, insisted on ranting to me about proposition 93--which would amend the CA constitution to change term limits in our state legislature. She said things like, "This is all dirty politics. I saw Don Perata walking down the street recently... he's such a crook." To a pollworker, this is electioneering. That is, advertisements, statements, etc. said or made within 100ft. of a polling place that could be considered as voter intimidation or persuasion. I told her that we are not permitted to allow substantive talk inside the polling place about issues on the ballot and that she would have to leave. She gave up on me at that point and said something about free speech and left. Little did she know that electioneering is one case where speech can be limited by the government.

Another voter came with her 18-year-old son who she wanted to cast a vote. I told them that, unless he's been registered in Alameda County before, he can't cast a vote. She said, "Man, you guys do this just to discourage us from voting!" I said, "Those are the rules, Ma'am". Then she pulled out an Obama political mailing--electioneering inside of a polling place--to claim that she's registered to vote. We didn't have her on the rolls. Luckily, I only had to ask one question: "Have you ever been registered to vote in Alameda County?" She said she had. So, I set her up with a provisional ballot and her vote will count.

Running Out of Materials

I didn't realize until later on that Alameda County was having difficulties involving running out of materials at other polling places. We ran out of provisional ballot envelopes and were very very close to running out of "non-partisan Democratic" ballots--the ballots non-partisan voters would request to cast a vote in the Democratic primary. Apparently, a court ordered that 14 precincts stay open 2 hours because of their having ran out of the non-partisan Democratic ballot style. I don't think we could have handled staying open any later.

As for the provisional ballot envelope issue, the RoV told us to have people sign and print their name and provide their address and that we would write a roman numeral on the ballot and next to their name on the provisional ballot log. This system seemed to work out well and had the added feature that we didn't hold up the line having to explain the provisional ballot envelope and process.

Ballot Accounting

Closing took much longer than in November 2006. The rate-limiter was counting the unused ballots. We had 1365 ballots in 54 styles delivered and we had to count the number left in each style before we could take our supplies to the drop-off location. This added about 1.5 hours onto normal closing procedures. Even after counting, it was clear we were way off on our ballot accounting. However, we were uncertain if it was our mistake or the RoV's mistake in accounting for how many ballots we were delivered.

Anyway, after packing everything up in various zip-lock bags and sealing each of them, we returned supplies to the drop-off location and I was home by about 11:30p.

Miscellaneous Observations

There was a surveillance camera in the polling place that was presumably recording people entering our polling place. I have no idea if it was turned off for election day.

We had separate ballot stock specifically for provisional ballots. This multiplied our number of available ballot styles by 2. It also meant, in certain cases, we were more likely to run out of ballots for a certain party (for example, we used a lot of provisional "non-partisan democratic" ballots).

This gives you a view from the ballot officer position--the person that gives out the ballots and activates the voter cards for the DRE. You can see a stack of ballot pads to the right.

I'm not sure what this thing is on the memory card (taken during closing). My best guess is that it's an inventory control RFID, a ground strap or a physical security mechanism. Cool!

We had a ton of provisional ballots cast and vote-by-mail (absentee) ballots dropped off.

California Secretary of State Deborah Bowen has begun a Top-To-Bottom (TTB) review of voting systems used in California. On Thursday of last week, the Secretary released a set of draft criteria to be used in the TTB review process ("Top-To-Bottom Review of Electronic Voting Systems Certified for Use in California Elections").

The Secretary sought public comment and we were given 6 days to submit documents. We're already seeing news stories about the comments submitted by CACEO (the California Association of Clerks and Election Officials); they are very concerned about how the TTB review will impact preparations for the new February 2008 primary ("E-voting machines face tough new standards").

I submitted comments today and I've made my comment submission available here in PDF: "Comments on California Secretary of State’s Draft Criteria for TTB Review".

Let me know if you have comments on my comments. I'd be especially interested in thoughts on the "learning bias" problem I discuss in the red teaming section; the idea is that it is hard to run a series of consistent red team exercises as the evaluators learn after each exercise.

If we would have had more time, I could have passed it around and brokered some institutional sign-offs. Alas, 6 days is a very short comment period!

I have always wanted to volunteer for an election and see what it's like to be on the ground, especially since election policy is a key part of my PhD thesis. Avi Rubin, the director of our ACCURATE grant, recently volunteered as a poll worker in a number of elections in Baltimore, MD. This inspired me to take the plunge and volunteer myself this time around. This past Tuesday, November 7, 2006, I was a poll inspector at Alameda County, California's precinct 22540 in Oakland, CA.

The day was long, from 6:00am to 10:00pm -- 16 hours. Naturally, a blog post about such a long day is going to also be long, so forgive me ahead of time.

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Cross-posted on the ACCURATE blog: "ACCURATE Submits Comments on VSTCP Manual"

Today ACCURATE submitted a public comment to the U.S. Election Assistance Commission (EAC) on the draft Voting System Testing & Certification Program (VSTCP) Manual. The Brennan Center for Justice at NYU School of Law, the Electronic Frontier Foundation, and the Verified Voting Foundation endorsed the comment.

The VSTCP Manual is an important document. When finalized, it will essentially be the rulebook that the EAC, vendors, and test labs will follow throughout the testing and certification process. The Manual also outlines the EAC's approach to publishing testing- and certification-related information, as well as how and when the EAC will solicit information from the public. The Manual also acknowledges some of the critical purposes of the federal process: to support state and local election officials and to increase voter confidence.

Although, as ACCURATE's comments acknowledge, the Manual takes some important steps toward serving these purposes -- for example, the EAC will publish test reports (albeit after redacting trade secret and confidential information) -- it doesn't go far enough. In many places, it is unclear about whether the EAC will publish certain information at all. In others, the Manual seems to say that the EAC will give information only to certain individuals or groups, or that it will accept information about testing and certification issues from a narrowly defined group.

In other areas of the testing and certification process, including specifying testing methods and increasing test lab accountability, the Manual doesn't do all that it could to increase voter confidence and support state and local election officials.

These issues are all covered in detail in ACCURATE's public comment.